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March 3, 2010 Americas: Managed Care

March 3, 2010









Americas: Managed Care







A front-line perspective on 2010 commercial price & product trends

Transcript from our sixth annual call with Steve Lewis

We hosted our seventh-annual industry expert conference call with Steve

Lewis, regional leader for the employee benefits practice of Willis, the third

largest insurance broker in the world. The call provided a front-line

perspective on 2010 industry pricing and product trends, with a focus on

the key middle-market segment of the industry.



A transcript of the conference call is provided in the body of this report.



Industry price discipline has strengthened further

Two years ago, Lewis and his team were one of the few industry sources

pointing (correctly) to aggressive pricing by the carriers in a lead up to

severe margin deterioration experienced in 1H2008. Then, a year ago,

Lewis and his team pointed to stronger pricing discipline by most of the

public companies (though with some outliers). Now, Lewis and his team

find price discipline has strengthened noticeably further.



Our view is that the industry downcycle is bottoming

We note that the improvement in commercial industry pricing discipline

has emerged from multiple industry sources over the past 18 months. Our

view is that it reflects a recovery from the severity of under-pricing during

the recent industry down-cycle that we think is now bottoming.



With the group, our favorite names are UNH and CI, both CL-Buy rated.

That said, ours is a sector call as we see a ‘rising tide lifting all boats’ as:

(1) the cycle turn shows in reserve building this year, with margin

expansion next year, (2) health reform uncertainty recedes, and (3) the

headwind to earnings from negative operating leverage eases as we

anniversary the severe member drop of 2009.









Matthew Borsch, CFA The Goldman Sachs Group, Inc. does and seeks to do business with

(212) 902-6784 | matthew.borsch@gs.com Goldman Sachs & Co. companies covered in its research reports. As a result, investors should

Mikael Landau be aware that the firm may have a conflict of interest that could affect

(212) 357-4835 | mikael.landau@gs.com Goldman Sachs & Co. the objectivity of this report. Investors should consider this report as

only a single factor in making their investment decision. For Reg AC

certification, see the end of the text. Other important disclosures follow

the Reg AC certification, or go to www.gs.com/research/hedge.html.

Analysts employed by non-US affiliates are not registered/qualified as

research analysts with FINRA in the U.S.







The Goldman Sachs Group, Inc. Global Investment Research

Goldman Sachs Global Investment Research 1

March 3, 2010 Americas: Managed Care









Transcript of conference call with Willis





Matt Borsch, Goldman Sachs:

Good morning, everyone. Thanks for joining us today for the Goldman Sachs Managed

Care Industry Expert Conference Call with Steve Lewis of employer benefit consulting firm

Willis. This will represent our 7th annual conference call with Steve Lewis.



Steve and his team have agreed to give us frontline perspective on 2010 managed care

pricing and product trends. As background, Willis is the third largest insurance broker in

the world with approximately 350 million in employee benefits revenues in North America

with a focus on the middle market employer segment.



That focus is particularly valuable given the lack of visibility on the segment from the other

health benefit consulting firms. And let me just elaborate on that. The context is that

national employer benefit consultants such as Hewitt, Mercer, Towers Perrin, and others

really focus their attention on the jumbo employer segment, which is overwhelmingly a

fee-based non-risk model.



However, the biggest earnings driver for the managed care companies are the fully insured

risk lives, and those are mostly through the small and mid-size employers that buy

through health insurance brokers. And we found that the brokers typically lack the scale

and sophistication to have a good perspective on macro industry trends.



However, as healthcare coverage has become more and more of a significant outlay for

employers, they've needed greater expertise but are often under served by the national

benefit consultants that focused on jumbo employers, so that's where Willis has built its

focus, serving as a high service benefit consultant for the middle-sized employers.



With that as an intro, let me reintroduce our guest speaker Steve Lewis, executive vice

president at Willis and regional practice leader. As background, Steve has 20 years of

experience in the employer benefits industry and previously served as a national account

executive with Oxford Health Plans, and also worked previously as a consultant with

Hewitt Associates.



With that, I'll turn it over to Steve to kick it off. Following that, I will serve as moderator for

a series of topical questions, and then, we will open it up to investor Q&A.







Steve Lewis, Willis HRH:

Good morning, Matt. Thank you again, for hosting us on this call. As always, I enjoy the

opportunity to do this with you each year. I also want to publicly acknowledge and thank

our team here for their support. The insight that I'll provide today and have previously

provided is largely the amalgamation of information that's developed from our team

working day in and day out with clients throughout the country.



I would add that my comments on this call will be directly based on my team's

experiences and do not necessarily reflect the experience of my Willis colleagues from

around the country.



BORSCH: Thank you for that, Steve. Let me jump right in here with, perhaps, the most

important question from the standpoint of institutional investors looking at the sector, and

that is, what are you seeing in terms of competition between the carriers, specifically

relative to last year or two years ago or whatever you want to use as the baseline, has

price competition increased or decreased?









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Price competition is LEWIS: As a specific answer to that, we would say, price competition is down from year

down from year ago ago. An overall theme that we would characterize this year, meaning, when I say this year,

even on the renewal the just completed January 1 renewals, and continuing up and through today. We feel this

business. is the most challenging environment for us and our clients in my 20 years in the business.



Not only is price competition down from year ago (when we had characterized last year's

price competition as being down from the prior year), but trend or (healthcare) inflation is

also up and appears to be rising. The incumbent carriers seem more willing than ever to

walk away from existing business resulting in some carrier changes.



And that's a significant adjustment from last year where we saw aggressive pricing on the

renewal front but not so much on the new business front. And then I'd say the other real

theme is we've seen some service levels that have gapped among few of the major players

which has further increased switching of carriers.



BORSCH: Let me move on to the next question here. If you look at the landscape, what

role do you see Third Party Administrators or TPAs playing in the competitive landscape?

And I guess this gets down to a related question if you could address between the

employer decision to self-fund or go with the fully insured purchase, are employers

shifting one way or the other.



LEWIS: Yes, I think taking the Third Party Administrator piece first, as in prior years, we've

seen little to no new penetration in our client base from the TPAs. There's still an

occasional place for them in the marketplace, but fewer and farther between in our opinion.



The networks have expanded to the extent across the country that there is now very

significant overlap, and the TPA discounts no longer really compete with what the major

managed care carriers have been able to do from a network standpoint.



With respect to the second part of your question (related to the self-funding versus fully

insured question), our clients primarily seem to want certainty in this economic

environment with respect to their healthcare spend.



So, unless they have either a reasonable track record of consistent and relatively

predictable claim patterns, clients that we expect to be fully insured are still largely biased

in that direction, and those that are on the fence as to whether they should be fully insured

or self-funded seem to, again, be biased more towards the fully insured product.



I would add that where we have had increased conversations is with our smaller client

segment that are increasingly frustrated with what we call blind renewals, meaning, no

claims data, and experiencing large increases on top of no claims data.

There's increased As a result, there's absolutely increased interest at the smaller client segment in evaluating

interest at the smaller potential self-funding with stop loss protection.

client segment in

evaluating self- BORSCH: Getting back into the topic of the competitive dynamics, can you touch on how

funding with stop loss criteria other than price play a role in carrier competition, whether that's in fully insured or

protection. self-insured or to the extent you draw a distinction, and to the extent that maybe that's

changed or not changed a little bit versus a year or two ago?



LEWIS: Yes, I think, as we've talked about in prior calls, price remains king in the middle

market, and is probably queen as well. Factors that can be a tie breaker other than price

would include network disruption to the specific population; market perception of the

competitive carrier's reputation; product flexibility, meaning willingness to allow

prescription drug carve-outs; ability to provide detailed reporting in a certain employee

population level, and funding arrangements offered. Not just the self-funded versus fully

insured argument but some of the hybrids or the more creative solutions within the fully

insured marketplace such as minimum premium or participating contracts in the fully

insured environment.







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March 3, 2010 Americas: Managed Care









Those things taken together can all factor in as tie breakers with respect to how employers

are evaluating carriers. But even still, price certainly remained the most significant driver.



I would add one thing; you asked how it's changed from prior years. I think last year on

this call, we talked specifically about the playing field that was fairly level on the service

end of the equation and as I mentioned at my opening comment, we have seen a bit of

gapping with respect to the services at some carriers. And that is driving employers to

certainly take a look at what's available on the marketplace. Then again, finding that

there's not a lot of aggressive price competition, the service disruption would have to be

fairly significant for somebody to move knowing that they're not going to be able to trade

down pricing very significantly.



BORSCH: Is it the case that the service disruptions that you've seen in some instances are

severe enough to reach the threshold where they switch?

In some cases, service LEWIS: The short answer is yes. We have seen some of that, and I think we've seen it at a

disruptions are leading lower price threshold than what we would've seen in the past.

to carrier switching at a

lower price threshold BORSCH: Let me move to a slightly different topic here, and obviously, the background

than in the past. here is the severe recession that was certainly having an impact when we talked a year

ago. But, now we've been through a lot more pain even though the economy is showing

signs of recovery. A lot of the impacts of these types of things are lagged.



So, I guess, it's sort of a general question how significant a role has the recession played

in the clients' product managed care strategies. And, what have you seen in terms of the

overall group enrollment changes related to that? It's sort of a high level question there,

but trying to understand what the impact of the severe recession has been on the way

employers look at things, buy things, and on enrollment?



LEWIS: Yes, I'd say, it's a great question and an interesting one particularly as we look at

this market. You mentioned the lag factor and the timing of the stock market drop of mid-

September 2008 was fairly late in the game to impact many employers' January 2009

strategies. So, most were not making any significant benefit changes, and/or made the

specific decision to hold the line when it came to health benefits at the end of the day due

to the freezes or cutbacks in other areas such as pay, 401K matches, and staffing levels.



So this year, I think, we saw a lot of employers saying, they were not going to make that

mistake again or very early on in 2009 looking back and saying, if I had to do it over again,

I probably would've made more drastic changes and not held the line with health benefits.



So, it is a bit ironic that they didn't – a lot of employers chose not to make the change last

year when we were in the deepest part of the recession. But this past year the renewal

process started much, much earlier for employers even knowing that the sooner they

started, the more impact trend uncertainty would have on their renewal.



Strategic planning just started much earlier, and employers wanted to see just about every

option under the sun both in terms of pricing, plan design, extreme options, really hedging

themselves trying to get some clarity as to what their options were with respect to health

benefits, because they didn't have clarity on either the direction of the market, the

economy, or even their own specific prospects.

It was without a So, as I mentioned at the outset, it was without a doubt the most challenging renewal cycle

doubt the most in my 20 years of this business with employers really struggling with how and what was

challenging renewal

going to drive their decision combined with the lack of aggressive and competitive pricing

cycle in my 20 years

in the marketplace.

of this business

I think, to your last point about how that may have impacted group enrollment, I'm not

sure I have anything significant statistically to share with you today. However, anecdotally,

I would say that enrollment is down across our book of business. We looked at 2009 going







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into the year and planned for the enrollment on our client base to be down 10 percent, and

I would say that was fairly accurate.



BORSCH: You alluded to something I just wanted to clarify – it may be that this isn't

measurable, but on the question of adverse selection (and, here, we're talking about the

employer market, not the individual market), you alluded to the potential that some

employees might be more likely not to take up coverage or, in fact, to discontinue

employer subsidized coverage, because even though it is subsidized it can be a very

sizable chunk out of their pay for a benefit package that may look less attractive after some

of the changes the employers have made.



So, to the extent you can infer if you're seeing any of that (and, related to that, the COBRA

uptake), has that been something that you measure? Has it come up in how the carriers

have presented their pricing? Finally, do you have any sort of visibility on whether that

trend is increasing or abating?



LEWIS: Let me take the first part on something I've alluded to about the potential for

adverse selection due to younger, healthier folks dropping and/or not selecting coverage

to begin with. You know, I think it depends a bit on the demographics of the population,

the type of industry; our clients really span just about every industry out there.

Adverse selection So is adverse selection on the rise in the group market? I would say it is, but I don't have

appears to be on the any data to back that up, but just based on the fact that the population is down 10 percent

rise in the group

across our book. And we look how the census in those client populations has shifted. I

market.

would suggest that there is: I don't want to overstate it because I'm not sure it's significant

at this point, but I certainly would see some creep, if you will on adverse selection.



I think that ties to your second point about COBRA uptake. We did not keep specific

statistics on the extent of COBRA uptake. But we certainly saw it across the board, in our

client base, and we certainly believe that it is impacting the pricing that our clients are

experiencing.



BORSCH: Given what you're facing from a more conservative underwriting environment

amongst the carriers, how are you leveraging or seeking to leverage current market

conditions to your clients' advantage in renewal negotiations?



LEWIS: Well, as stated the outset, and probably ad nauseum at this point and it's been a

tough year.



Carriers were very selective in going after new business, and incumbents were willing to

walk away from existing clients. So we had to be incredibly creative in our negotiation

tactics as well as in our strategic advice with clients. And again, it was something that

fortunately for us, in the process, we did start early and while it consumed a lot of energy

from all of the stakeholders it was probably the year of creativity.



With respect to negotiation tactics, one of the interesting things is that we seemed to have

seen a bit of a bifurcation in the marketplace at the plus or minus 300-employee size.



In the groups under 300 employees, many of them don't have or are unable to get control

of their claims data either as a result of the products they’ve purchased or just

underwriting guidelines at the carrier level where they don't have complete control of their

claims data. In that under 300-market place, there was very little competition and very high

renewals right out of the gates.



However, in the over 300-employee market, if the claims data was available and in a

detailed way and you could make a story about that claim's pattern and possibly make

adjustments for a spike – a one-time spike. Then, you would see competition pick up. But

again, it was very selective and certainly not anything we would characterize as overly

aggressive.







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March 3, 2010 Americas: Managed Care









BORSCH: This lead in to the next question: Can you generalize about what is the average

rate increase that you're observing: both the initial carrier request and the final end point,

post negotiation and plan changes? And can you tell us about the extent of plan benefit

reductions in achieving final results for your clients?



LEWIS: Averages are tough, you're right, and probably don't tell a very good story and

some clients look at that and say, wow, how did you get that average? I must've been the

high person. But the range was all over the place and fairly extreme. I'd say we settled in a

range, on our book of business, from a 5% reduction to a 50% increase.



But generally speaking, we were in low to mid-teens out of the gates, and this is where the

real challenges begin. Because negotiations generated no more than one to one and a half

points with no plan changes. And so it's almost like you were getting a first and final and

you had to dig through the renewals to find a mistake.



That's less movement than we've had in each of the prior years and certainly, not turned in

the right direction from our clients' perspective.



BORSCH: But on the benefit plan changes that your clients have implemented, would you

say those are more substantial today than what you saw a year ago?

Benefit plan changes LEWIS: I would say that incrementally the changes are more substantial, but visually to

are more substantial employees, they're fairly significant. You know, just about everybody did something this

than a year ago. year. And it did vary as you would imagine by the extent of the renewal and the existing

plan structure, but things like 100% co-insurance are virtually gone.



BORSCH: Yes.

LEWIS: What we saw was a lot of tweaking, where we'd see the employers bifurcating the

primary and specialist co-payments, adding prescription drug deductibles on top of co-

payments, and really focusing on plan changes first and foremost before looking at

impacting employee contributions.



INVESTOR QUESTION: You talked about client renewal process starting earlier as the

planning process started earlier. Does that mean the contracts are actually being signed

earlier and therefore the carriers will have more visibility into the premium yield this year

compared to previous years?



LEWIS: Great question. The answer is no. The contracts are not renewing any earlier, just

the negotiation process. So, in our world, generally speaking, we would look to get a

renewal (depending on the size of the group) from 90 to 120 days before the expiration of a

renewal.



This year, clients were looking to us (and to a certain extent from the carriers) to extend

that to 6 months out: where we start predicting where the renewal is going to end up. And

to the extent that the carriers were willing to provide a preliminary renewal, they have to

load in a lot of trend because they have to make guesses on the claims going forward.



And then as you move closer to the expiration date, they offset trend with the wrong

claims experience. So nobody was renewing or signing contracts earlier, they were just

dragging the process out much, much longer from both the carrier side and the employer

side.



BORSCH: Let me ask a question, and hopefully, this is isn't repetitive, but in the market

studies that you've reviewed, how wide have the gaps been between the different carriers?

Have you noted one carrier or groups of carriers relative to the others that have been

especially aggressive or perhaps overly conservative that stand out?









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March 3, 2010 Americas: Managed Care









Generally not seeing LEWIS: The short answer is no. I think in particular situations, we've seen a couple of

one carrier being more carriers be more aggressive than others. But I'm putting quotes around more aggressive

aggressive than the because we're generally in the three to five percent range between pricing from where an

others. incumbent renewal might be and what might be considered aggressive.



Now, there were few exceptions on some of our larger middle market clients, as I've

mentioned earlier, with very clean data, stable business, perhaps a one-year blip with the

incumbent that cause the incumbent to get skittish and want to shut the business and a

competitor to come in and price it more aggressively. But as a general rule, Matt, we were

in a pretty tight range during the market study process.



BORSCH: We've talked in prior years about tracking the gradually growing interest in the

consumer-directed health plan products. Where you would say we stand now? Have you

seen the uptake increase meaningfully as a result of all the pressure of the last year? And,

you know, if you can offer a little bit of a forecast, do you think that may change going into

2011?

Surprisingly, not a LEWIS: Yes. Surprisingly, we have not seen a significant shift towards the consumer

significant shift directive plan. Across the board, it's now an option for most employer groups. And the

towards the consumer clients that have offered it for the longest period of time (call it three-plus years) are now

directed plans. exceeding double-digits, but that's the low double-digits for enrollment as an option.



New offerings continue to generate very low enrollments out of the gates with still almost

no full replacements at this point. I think the one shift we have seen is a swing towards

health reimbursement accounts and away from health savings accounts that more

employer-friendly. And employers are doing more to tie their wellness rewards and

strategies to their health reimbursements accounts.



So I'd say if you ask about a crystal ball, really the tying of wellness and to focus on

improving the health of a population, then consumer health plans tied to an HRA account

is where we see this market moving and really the potential for the biggest surge.



BORSCH: Let me just conclude with one last one I want to throw at you here, Steve. This

has been tremendous insight that you've brought for us so I want to thank you. On health

reform, obviously, this is a huge thing in the background but it's a practical matter, but it

doesn't necessarily have that much day-to-day impact on things.



But to what extent is health reform something that the employers are looking at? Are they

talking to you about it? Have you got ‘two cents’ on where opinions fall amongst

employers about what they would like to see happen relative to what's been presented in

Washington.



LEWIS: Yes, we are talking to our clients a lot about it. There is a lot of what I would call

academic interest at this stage of the game. They're very mixed in their reaction, quite

candidly consistent with what we're seeing in the polling numbers by party lines.



I think most people would acknowledge that there's a need for healthcare reform,

employers continue to be very frustrated. So when they look at what the Obama

administration and the Democratic Majority state as their goals to increase access and

lower cost and rail at what maybe termed oligopolistic behavior of carriers in certain

markets, I think employers really buy in to that message and have much of that frustration

and anger at our lack of solutions.



But I would also say that many of them still view the legislation and the partisanship

coming out of Washington as possibly the medicine worse than the disease. So, many

employer groups that we're talking to feel like it would be a shame to lose an opportunity

to do something with respect to healthcare reform. But many are starting to feel like

maybe nothing is better than something in this current environment.









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March 3, 2010 Americas: Managed Care









BORSCH: This is probably a good place to end our call. Steve, thank you very much. This

is really a great frontline perspective on industry trends and I want to thank you and your

firm Willis, and also thank our investor clients who dialed in.



LEWIS: Thank you, Matt. I appreciate it.









Rating and pricing information

CIGNA Corp. (B/A, $34.44) and UnitedHealth Group (B/A, $33.95).









Goldman Sachs Global Investment Research 8

March 3, 2010 Americas: Managed Care









Reg AC

We, Matthew Borsch, CFA and Mikael Landau, hereby certify that all of the views expressed in this report accurately reflect our personal views about

the subject company or companies and its or their securities. We also certify that no part of our compensation was, is or will be, directly or indirectly,

related to the specific recommendations or views expressed in this report.









Investment Profile

The Goldman Sachs Investment Profile provides investment context for a security by comparing key attributes of that security to its peer group and

market. The four key attributes depicted are: growth, returns, multiple and volatility. Growth, returns and multiple are indexed based on composites

of several methodologies to determine the stocks percentile ranking within the region's coverage universe.

The precise calculation of each metric may vary depending on the fiscal year, industry and region but the standard approach is as follows:

Growth is a composite of next year's estimate over current year's estimate, e.g. EPS, EBITDA, Revenue. Return is a year one prospective aggregate

of various return on capital measures, e.g. CROCI, ROACE, and ROE. Multiple is a composite of one-year forward valuation ratios, e.g. P/E, dividend

yield, EV/FCF, EV/EBITDA, EV/DACF, Price/Book. Volatility is measured as trailing twelve-month volatility adjusted for dividends.









Quantum

Quantum is Goldman Sachs' proprietary database providing access to detailed financial statement histories, forecasts and ratios. It can be used for

in-depth analysis of a single company, or to make comparisons between companies in different sectors and markets.









Disclosures



Coverage group(s) of stocks by primary analyst(s)

Matthew Borsch, CFA: America-HCManaged, America-Healthcare Services:Facilities.

America-HCManaged: Aetna, Inc., AMERIGROUP Corp., Centene Corp., CIGNA Corp., Coventry Health Care, Inc., Health Net, Inc., HealthSpring Inc.,

Humana Inc., Magellan Health Services, Inc., Molina Healthcare, Inc., UnitedHealth Group, Universal American Corp., WellCare Health Plans, Inc.,

WellPoint, Inc..

America-Healthcare Services:Facilities: AmSurg Corp., Community Health Systems, Inc., Emergency Medical Services Corp., Health Management

Associates, Laboratory Corporation of America Holdings, LifePoint Hospitals, Inc., NightHawk Radiology Holdings, Inc., Quest Diagnostics

Incorporated, Select Medical Holdings Corp., Team Health Holdings, Inc., Tenet Healthcare Corp., Universal Health Services, Inc., Virtual Radiologic

Corp..



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disclosures as to any applicable disclosures required by Japanese stock exchanges, the Japanese Securities Dealers Association or the Japanese

Securities Finance Company.



Ratings, coverage groups and views and related definitions

Buy (B), Neutral (N), Sell (S) -Analysts recommend stocks as Buys or Sells for inclusion on various regional Investment Lists. Being assigned a Buy

or Sell on an Investment List is determined by a stock's return potential relative to its coverage group as described below. Any stock not assigned as

a Buy or a Sell on an Investment List is deemed Neutral. Each regional Investment Review Committee manages various regional Investment Lists to

a global guideline of 25%-35% of stocks as Buy and 10%-15% of stocks as Sell; however, the distribution of Buys and Sells in any particular coverage

group may vary as determined by the regional Investment Review Committee. Regional Conviction Buy and Sell lists represent investment

recommendations focused on either the size of the potential return or the likelihood of the realization of the return.

Return potential represents the price differential between the current share price and the price target expected during the time horizon associated

with the price target. Price targets are required for all covered stocks. The return potential, price target and associated time horizon are stated in

each report adding or reiterating an Investment List membership.

Coverage groups and views: A list of all stocks in each coverage group is available by primary analyst, stock and coverage group at

http://www.gs.com/research/hedge.html. The analyst assigns one of the following coverage views which represents the analyst's investment outlook

on the coverage group relative to the group's historical fundamentals and/or valuation. Attractive (A). The investment outlook over the following 12

months is favorable relative to the coverage group's historical fundamentals and/or valuation. Neutral (N). The investment outlook over the

following 12 months is neutral relative to the coverage group's historical fundamentals and/or valuation. Cautious (C). The investment outlook over

the following 12 months is unfavorable relative to the coverage group's historical fundamentals and/or valuation.

Not Rated (NR). The investment rating and target price have been removed pursuant to Goldman Sachs policy when Goldman Sachs is acting in an

advisory capacity in a merger or strategic transaction involving this company and in certain other circumstances. Rating Suspended (RS). Goldman

Sachs Research has suspended the investment rating and price target for this stock, because there is not a sufficient fundamental basis for

determining an investment rating or target. The previous investment rating and price target, if any, are no longer in effect for this stock and should

not be relied upon. Coverage Suspended (CS). Goldman Sachs has suspended coverage of this company. Not Covered (NC). Goldman Sachs does

not cover this company. Not Available or Not Applicable (NA). The information is not available for display or is not applicable. Not Meaningful

(NM). The information is not meaningful and is therefore excluded.



Global product; distributing entities

The Global Investment Research Division of Goldman Sachs produces and distributes research products for clients of Goldman Sachs, and pursuant

to certain contractual arrangements, on a global basis. Analysts based in Goldman Sachs offices around the world produce equity research on





Goldman Sachs Global Investment Research 10

March 3, 2010 Americas: Managed Care









industries and companies, and research on macroeconomics, currencies, commodities and portfolio strategy. This research is disseminated in

Australia by Goldman Sachs JBWere Pty Ltd (ABN 21 006 797 897) on behalf of Goldman Sachs; in Canada by Goldman Sachs & Co. regarding

Canadian equities and by Goldman Sachs & Co. (all other research); in Hong Kong by Goldman Sachs (Asia) L.L.C.; in India by Goldman Sachs

(India) Securities Private Ltd.; in Japan by Goldman Sachs Japan Co., Ltd.; in the Republic of Korea by Goldman Sachs (Asia) L.L.C., Seoul Branch; in

New Zealand by Goldman Sachs JBWere (NZ) Limited on behalf of Goldman Sachs; in Russia by OOO Goldman Sachs; in Singapore by Goldman

Sachs (Singapore) Pte. (Company Number: 198602165W); and in the United States of America by Goldman Sachs & Co. Goldman Sachs

International has approved this research in connection with its distribution in the United Kingdom and European Union.

European Union: Goldman Sachs International, authorized and regulated by the Financial Services Authority, has approved this research in

connection with its distribution in the European Union and United Kingdom; Goldman Sachs & Co. oHG, regulated by the Bundesanstalt für

Finanzdienstleistungsaufsicht, may also distribute research in Germany.



General disclosures

This research is for our clients only. Other than disclosures relating to Goldman Sachs, this research is based on current public information that we

consider reliable, but we do not represent it is accurate or complete, and it should not be relied on as such. We seek to update our research as

appropriate, but various regulations may prevent us from doing so. Other than certain industry reports published on a periodic basis, the large

majority of reports are published at irregular intervals as appropriate in the analyst's judgment.

Goldman Sachs conducts a global full-service, integrated investment banking, investment management, and brokerage business. We have

investment banking and other business relationships with a substantial percentage of the companies covered by our Global Investment Research

Division. Goldman Sachs & Co., the United States broker dealer, is a member of SIPC (http://www.sipc.org).

Our salespeople, traders, and other professionals may provide oral or written market commentary or trading strategies to our clients and our

proprietary trading desks that reflect opinions that are contrary to the opinions expressed in this research. Our asset management area, our

proprietary trading desks and investing businesses may make investment decisions that are inconsistent with the recommendations or views

expressed in this research.

We and our affiliates, officers, directors, and employees, excluding equity and credit analysts, will from time to time have long or short positions in,

act as principal in, and buy or sell, the securities or derivatives, if any, referred to in this research.

This research is not an offer to sell or the solicitation of an offer to buy any security in any jurisdiction where such an offer or solicitation would be

illegal. It does not constitute a personal recommendation or take into account the particular investment objectives, financial situations, or needs of

individual clients. Clients should consider whether any advice or recommendation in this research is suitable for their particular circumstances and,

if appropriate, seek professional advice, including tax advice. The price and value of investments referred to in this research and the income from

them may fluctuate. Past performance is not a guide to future performance, future returns are not guaranteed, and a loss of original capital may

occur. Fluctuations in exchange rates could have adverse effects on the value or price of, or income derived from, certain investments.

Certain transactions, including those involving futures, options, and other derivatives, give rise to substantial risk and are not suitable for all

investors. Investors should review current options disclosure documents which are available from Goldman Sachs sales representatives or at

http://www.theocc.com/publications/risks/riskchap1.jsp. Transactions cost may be significant in option strategies calling for multiple purchase and

sales of options such as spreads. Supporting documentation will be supplied upon request.

Our research is disseminated primarily electronically, and, in some cases, in printed form. Electronic research is simultaneously available to all

clients.

Disclosure information is also available at http://www.gs.com/research/hedge.html or from Research Compliance, One New York Plaza, New York,

NY 10004.

Copyright 2010 The Goldman Sachs Group, Inc.

No part of this material may be (i) copied, photocopied or duplicated in any form by any means or (ii) redistributed without the prior

written consent of The Goldman Sachs Group, Inc.









Goldman Sachs Global Investment Research 11


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